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. ..~ 2 copy of the certificate of dissolution, it is certain that an Agreement and Plan of Reorganization was executed by Thompson Creek Coal and Coke Corp. and North American Resources Corporation between June 11, 1969, and December 16, 1970. Thompson Creek Coal and Coke Corp. filed Articles of Dissolution with the Colorado Secretary of State on December 17, 1970, and the corporation ceased to exist on that date. There is no record of the Agreement in the case file until March 19, 1973, when Mr. Albert M. Keenan notified the Colorado State Office that the assets of Thompson Creek Coal and Coke Corp., including coal lease D-037766, "were acquired by North American Resources Corporation." He did not inform BLM that Thompson Creek Coal and Coke Corp. no longer existed as a legal entity. The Colorado State Office notified North American Resources Corporation in March 1973 that a transfer of a coal lease had to be filed for approval by this office. Another request to file the assignment was made July ]0, 1973. That North American never filed the requested documentation is evidenced by a letter from the Colorado State Office to Mr. Keenan on January 7, 1975, stating "if North American will file the proper documents and bond with this office, we could take action toward approving the assignment." There is no indication in the case file that this matter was pursued any further by either Mr. Keenan or BLM. The Colorado State Office readjusted coal lease D-037766 effective November 5, 1987, by our final decision dated April 21, 1988. Until Mr. Whalen sent his letters of inquiry in 1989, the BLM had no record that its lessee of record was a dissolved corporation and that the legal stams of the lease might be questionable. Section 30 of the Mineral Leasing Act of 1920 (MLA), as amended (30 U.S.C. 187 (1970)), provides that no lease issued under the Act "shall be assigned or sublet, except with the consent of the Secretary of the Interior." In 1970, the coal leasing regulations provided that the "transferor of a permit or lease ...and his surety will continue to be responsible for the performance of any obligation under the pennit or lease until the effective date of the approval of the transfer. If the transfer is not approved, their obligation to the United States shall continue as though no such transfer had been filed for approval." 43 CFR 3134.1(b) (1969). Neither the MLA nor the coal leasing regulations made provisions for a situation where a lease transfer could not be recognized and the transferor and lessee of record had ceased to exist. Because Thompson Creek Coal and Coke Corp. dissolved long before BLM was notified, state law regarding corporations must be considered. The Colorado Revised Statutes provide that . after filing a statement of intent to dissolve with the Secretary of State and after payment of all obligations, assets of the corporation aze to be distributed among its shareholders according to their respective rights and interests. Colo. Rev. Stat. 7-8-105 (1989). BLM has no document specifying the distribution of the remaining assets of Thompson Creek. The Grand Junction District Office, however, has provided a copy of a letter dated May 26, 1982, from Catherine T. Keenan, Personal Representative for the Estate of Albert M. Keenan, to the District Mining Supervisor, Minerals Management Service, in which she states that Mr. Keenan was "the largest stockholder of that corporation." BLM's records and the Certificate of Dissolution confirm that Mr. Keenan was President of the corporation at the time of its dissolution.